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Ollnova v. ecobee: Timing Rules Survive Alice

Federal Circuit, decided 4 June 2026. Read from the decision; quotations verified against its text.

Read this with GoTV v. Netflix. Together these answer what engineers actually ask, which is what kind of detail counts. Not the label "architecture," but the interval and the threshold.
Holding

On June 4, 2026 the Federal Circuit affirmed that claims requiring a controller to monitor a sensor only during a polling interval and transmit only during a transmission interval and only when a value falls outside a predetermined range are directed to a specific technological improvement rather than an abstract idea, while separately vacating the $11.5 million verdict because the jury was never told what the abstract idea was.

Ollnova sued ecobee over smart thermostats and won $11.5 million. The Federal Circuit took the verdict away and left Ollnova with a doctrinal win worth having.

Two of its patents are eligible under § 101 because the claims impose timing constraints and a conditional transmission trigger, which the court called a particular technique governing when and how information is transmitted.

The verdict fell for two procedural reasons: the jury decided the inventive-concept question without ever being told what abstract idea it was measuring against, and one verdict-form question covered infringement of all the patents at once.

What This Case Is Not

"Ollnova won" is wrong in the way that matters. It won a step one ruling and lost an $11.5 million verdict in the same opinion. Reporting the eligibility holding without the vacatur gives a false picture of what happens when you assert patents, and the procedural half is arguably the more useful lesson.
  • It does not mean timing constraints are always sufficient. They were sufficient on these claims.
  • It does not tell you whether your claims recite a technological improvement.
  • Winning eligibility is not winning the case, which this opinion demonstrates in both directions at once.

Educational, not legal advice. Whether any particular claim is eligible under § 101 is a legal conclusion a qualified patent attorney reaches on the actual claims.

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